The Ministry of Finance announced on 6 March 2015 amendments to the transfer pricing rules governing non-arm’s length transactions of profit-seeking enterprises. This amendment coming 10 years after the promulgation of the transfer pricing assessment rules which are made in response to international trends and aim to enhance audit effectiveness, to simplify the advance pricing agreement (APA) application procedures, and to reduce double taxation risk of multinational enterprises. Also the transfer pricing rules specifically include provisions relating to business restructuring.
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